In the 1980s the US planned to reform national transfer pricing regulations
so that profit comparison would be explicitly recommended. The
motivation for this unilateral move was that the US government was concerned
with two related problems: namely, that US MNEs were shifting
profits abroad by underreporting prices charged for trademarks and other
intellectual property to their overseas manufacturing subsidiaries; and that
foreign MNEs – especially from Japan – were overpricing imports to their
American subsidiaries in order to lower their American tax bill (Webb,
2001: 137–40).11